Chi. Tile Inst. Welfare Plan v. Regal Builders, Inc.

Full title: CHICAGO TILE INSTITUTE WELFARE PLAN, CHICAGO TILE INSTITUTE PENSION PLAN…

Court: United States District Court, Northern District of Illinois

Date published: Jun 21, 2023

22 CV 5754 (N.D. Ill. Jun. 21, 2023)

Opinion

22 CV 5754

06-21-2023

CHICAGO TILE INSTITUTE WELFARE PLAN, CHICAGO TILE INSTITUTE PENSION PLAN, and the CERAMIC TILE AND TERRAZZO LOCAL 21 B.A.C. ANNUITY PLAN, Plaintiffs, v. REGAL BUILDERS I, LLC., Defendant.

Michael J. McGuire Raymond J. Sanguinetti Marco, McGuire & Arreola, LLC Rathje Woodward, LLC

SEEGER, JUDGE

Michael J. McGuire

Raymond J. Sanguinetti

Marco, McGuire & Arreola, LLC

Rathje Woodward, LLC

AGREED MOTION FOR ENTRY OF JUDGMENT ORDER

SEEGER, JUDGE

Plaintiffs, CHICAGO TILE INSTITUTE WELFARE PLAN, et.al. by and through its attorneys, Michael J. McGuire, and Marco, McGuire & Arreola, LLC, and Defendant, REGAL BUILDERS I, LLC by and through its attorney Raymond J. Sanguinetti, and Rathje Woodward LLC, move this Honorable Court to enter an Agreed Judgment Order against the Defendant, REGAL BUILDERS I, LLC, and in support states as follows:

1. Plaintiffs filed their First Amended Complaint on March 24, 2023, alleging that the Defendant failed to submit reports and contributions to the Plaintiff Trust Funds for the months of June 2022 through December 2022.

2. As a result of the delinquency, the Defendant owes the Plaintiff Trust Funds $377,910.87 in delinquent contributions, interest, liquidated damages, attorney fees and costs for the time period of June 2022 through December 2022.

3. The Parties have had the benefit of counsel and this matter has been reviewed by all parties, including the principle of the Defendant corporation.

4. Per this Court's Order of June 20, 2023, counsel for the Defendant is submitting a statement confirming that the Defendant agrees to entry of judgment, including the proposed judgment in the amount of $377,910.87. A true and correct copy of this statement is attached as Exhibit 1.

5. Plaintiffs and Defendant have agreed that a Judgment Order should be entered against the Defendant for the total amount due in the amount of $377,910.87 to resolve the litigation.

WHEREFORE, Plaintiffs and Defendant request that this Court enter an Agreed Judgment Order in the amount of $377,910.87 against the Defendant, REGAL BUILDERS I, LLC.